On September 5, 2012, the HHS published a final rule that establishes new requirements for administrative transactions that are intended to improve the utility of the existing HIPAA transactions and reduce administrative burden and costs. Specifically, the rule adopts the standard for a national unique health plan identifier (HPID) and establishes requirements for the implementation of the HPID. Health plans generally must obtain an HPID by November 5, 2014, although the deadline for small health plans to obtain an HPID is November 5, 2015. Covered entities must use HPIDs in the standard transactions on or after November 7, 2016. HHS estimates that implementing the HPID will result in net savings of approximately $1.3 billion to $6 billion for the entire health care industry over 10 years. In addition, the rule establishes a data element that will serve as an “other entity identifier” (OEID), or an identifier for entities that are not health plans, health care providers, or individuals, but that need to be identified in standard transactions. The rule also specifies the circumstances under which an organization covered health care provider must require certain noncovered individual health care providers who are prescribers to obtain and disclose a National Provider Identifier (NPI); the compliance date is for this provision is May 6, 2013.
The rule also postpones the implementation date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD–10–PCS) for inpatient hospital procedure coding, from October 1, 2013 to October 1, 2014. This delay is intended to give covered entities more time to prepare and fully test their systems to ensure a smooth transition to these new code sets. CMS notes that any extension of the current limited freeze on code updates based on the delay adopted in the rule will be discussed and decided by the ICD-9-CM Coordination and Maintenance Committee.